MEMORANDUM

To: Jodi Howard, US EPA/SPPD/CCG

From: Colin Hayes, ERG

Date: December 22, 2009

Subject: Summary of November 23, 2009 Meeting Between US EPA and Shintech

On November 23, 2009, US EPA met with representatives of Shintech to discuss 

Shintech’s proposal regarding the Section 114 survey response and testing for their facilities. 

The meeting was held at US EPA’s Research Triangle Park location. The following individuals 

were present:

Colin Hayes, ERG

Jodi Howard, US EPA/OSQPS

Jim Hodges, Shintech - Freeport

Mark Garza, Shintech

Michael Bracy, The EOP Group (consultant for Shintech)

Michael O’Bannon – The EOP Group (consultant for Shintech)

Richard Mason, Shintech

David Wise, Shintech - Addis

Penny Lassiter, US EPA/OAQPS

Peter Tsirigotis, US EPA/OAQPS

KC Hustvedt, US EPA/OAQPS

Nick Parsons, US EPA/OAQPS

The following individuals participated via teleconference:

Jennifer Gibbs, US EPA/Region 6

Patricia Welholm, US EPA/Region 6

Marcia Moncrieffe, US EPA/Region 6

David Garcia, US EPA/Region 6

Mark Kataoka, US EPA/OGC

Ed Messina, US EPA/OECA

Charlie Garlow, US EPA/OECA

David Tidholm, Shintech - Counsel

Marcia Mia, US EPA/OECA

Following general introductions, EPA opened the meeting by outlining the nature of what SPPD 

does and the Section 112 requirements.
2

EPA noted that the PVC standard that was issued was ultimately vacated and EPA ended up 

settling on a deadline suit to reinstitute standards for the PVC manufacturing industry.

EPA added that multiple standards have been vacated or partially vacated recently and that 

the PVC vacatur took away a lot of the flexibility in setting standards.

EPA stated that because there are less than 30 facilities, the MACT standard will be based on 

the performance of the best 5 facilities.

EPA added that Shintech’s Plaquemine facility is the newest plant and Shintech also owns 

some other newer plants. EPA wants to capture those for this rulemaking.

EPA noted that the court did leave EPA some flexibility. EPA could incorporate variability 

and the ability to subcategorize based on size of plant.

EPA indicated a proposal date of September 2010, with a promulgation date of July 2011.

Shintech stated that the company wants to support EPA’s effort and that the promulgation of 

a new standard for the industry is a good idea.

Shintech added that it is unique; there are differences in its processes that are important to 

understand.

Shintech added that when looking at the cost of conducting the survey and the testing, there is 

little to gain

Shintech then gave a presentation. A copy of the presentation is included as Appendix A to 

this memorandum.

Shintech has three U.S. plants: Freeport, TX, Addis, LA, and Plaquemine, LA

Plaquemine is the only integrated site with VCM production. Part of the plant was 

started up late last year. The plant is currently manufacturing PVC as of September of 

last year.

VCM is piped into the Freeport and Addis plants.

All three plants make the same materials and use the same modular process.

The Shin-etsu process was licensed in 1974

Reactor-suspension resin; equal parts of VCM and water; some initiator.

The reaction is stopped at 60-80% completion. The slurry is discharged to a slurry 

tank. 

There is a slurry tank, slurry column, recovery process, and centrifuging/drying.

The identical process is used in all three facilities, even though it dates back to 1974.

Shintech stated it is constantly upgrading computers and technologies.

Shintech noted that about 70% of the product goes to the construction industry (pipe, 

vent pipe, home building, PVC conduit) and about 40% goes into packaging, meat 

wrap, IV tubing, blood bags, etc.
3

EPA inquired as to the difference between ―grade‖ of resin and ―type‖ of resin.

Shintech responded that the resin grades are a function of chain length. Shintech has less 

than 12 grades—SE950 is the predominant grade (―950‖ length of polymer chain—950 units 

long). SE950 is the primary resin used for extrusion application (pipe, siding, windows, 

doors, extrusion apps) and constitutes about 70% of production.

EPA asked if Shintech has any emissions information according to the different grades being 

produced. Shintech responded that they only have monitors on thermal oxidizers to meet the 

10 ppm limit.

Shintech noted that there is no distinctive difference in the maw materials for the different 

grades. SE950 would be a conservative grade to test for and would be the ―best picture‖ for 

the 114 request. Shintech added that they have only looked historically at vinyl chloride but 

are confident that SE950 would be a conservative grade.

EPA noted that it set limits like that back in National Lime and added that it can’t set 

emissions limits based on the highest emissions.

Shintech stated that other grades (other than SE950) only constitute about 30% of 

production—PVC is a monthly product.

Shintech noted that reaction time (what determines the chain length) and chemicals going 

into the process are the same—inputs and outputs are the same. May only be a 1-2% 

difference in emissions between grades.

EPA asked whether there is historical data to support the 1-2% difference in emissions?

Shintech stated that one production unit may run only SE950 all the time and another unit 

might be dedicated to running other grades.

EPA stated that it is concerned that the process can significantly impact emissions.

Shintech stated that its production units range from 1974-2008 and they went back to older 

units to retrofit with current technology. Shintech added that its Addis and Plaquemine 

facilities are practically identical. The company retrofitted 2 of 3 plants in Addis to use same 

slurry strippers as Plaquemine.

EPA asked if there were scrubbers after the incinerators.

Shintech noted that 99% of what is incinerated is nitrogen. There is a quench using an

alkaline solution and the scrubber is downstream. Want to recover as much vinyl chloride as 

possible. The company uses condensers and chilled scrubbers.

Shintech stated it is on track to do sampling at its Freeport facility.

Shintech stated that the sites are identical except for size. In terms of size, Addis and 

Plaquemine are the same; Plaquemine has other waste streams going into the incinerator.

Shintech noted that EPA did some wastewater dioxin testing a few years ago.

EPA stated that unless it has data, the new limits will have to be complied with at all times. 

Just like HON rule.
4

Shintech noted that Louisiana and Texas have differences in permitting (emission limits).

Shintech noted that most SSM emissions are tied to planned shutdown and maintenance

activities and added that this information will be provided in the 114 request.

EPA clarified that the company doesn’t need to test only one grade for 30 days---can do 

multiple grades; in fact this would be desired. The same number of samples—just additional 

analysis.

Shintech stated that it wants to satisfy the section 114 at only the one site.

EPA expressed its concern that two sites not testing are in fact the newest plants in the

industry. EPA has to set limits on the best performing 5. EPA added that those two plants 

would likely fall into the top five. EPA added that this, combined with the SE950 grade 

issue, creates concerns.

EPA added that the data may be exactly the same but the Agency cannot determine that until 

it gets the data and looks at it.

Shintech stated that the data is going to be the same whether it tests one facility or all three.

EPA stated that historically, many MACT standards used engineering judgment in setting the 

standards; the courts basically said they did not care about engineering judgment. EPA must 

use actual data and the only way to do it is through Section 114 requirements.

EPA added that if there is redundancy (as shown by the data), then EPA will set standards 

based on that; but this fact has to be proven and cannot be based on assumptions or 

judgments.

Shintech stated that the issue is primarily from a cost standpoint; it is not a good time.

EPA asked why Shintech only submitted a test plan for Freeport? EPA stated that it has 

nothing to compare it to without testing plans for the other two plants.

Shintech responded by stating that the testing protocol would have been the same at all three 

plants and EPA can superimpose the test plan on all three plants.

EPA asked if Shintech is planning on doing three surveys.

Shintech indicated that is their intent.

EPA stated that some industries have voluntarily started looking at things like alternative 

surrogates, CO equating to VOC, etc. with the thinking that their lives might be better down 

the road. EPA is open to considering better ways of doing things or looking at other data, 

even if EPA hasn’t asked for it.

Shintech stated that industry feels that VCM is a good surrogate; the problem is that industry 

has to go through a case-by-case MACT every time they want to do something.

EPA noted that time is winding down. Shintech stated they had a better understanding of the 

issues and will get back to EPA on day next week. EPA agreed this timeframe was 

acceptable.
5

Appendix A

Shintech Presentation Slides
PRESENTATION F

EPA PVC MACT 

Meeting

November 23, 2009
 Shin-Etsu Chemical - Shintech’s 

Parent Company

 PVC Capacity and Market Summ Technology overview Shintech’s history Process discussion PVC MACT testing request
 SHINTECH - wholly owned subsidiary of SHIN-ETSU Chemical  SHIN-ETSU Group (As of March 31, 2008)

1) $13.7 Billion Global Sales(JPY100 = US$1.00)2) 20,241 Employees, production bases in 16 countries

 Major Product and Market Positions

World Wide

PVC(Polyvinyl Chloride) 1Silicon Wafers 1Cellulose Derivatives 1Silicones 4 (No.1 in Japan)Synthetic Quartz Glass 1 (for photomasks)Rare Earth Magnets 1 (for hard disc drive

SHIN-ETSU AND ITS GROUP
SHINTECH GLOBAL PVC

TECHNOLOGY SUPPORT

SHINTECH

TS+QC

TX & LA

SHIN-ETSU

PVC R&D CENTER

KASHIMA, JAPAN

C.I.R.E.S.

TS + QC

ESTARREJA,

PORTUGAL

SHIN-ETSU PVC EUROPE

TS+QC

NETHERLANDS

SHIN-ETSU

KASHIMA, JAPAN

CU

SHIN-ETSU

POLYMER

PILOT PLANT & PROCESS EQUIPMENT
SHIN-ETSU GROUP PVC WORLD CAPACI

 SHINTECH U.S.A. 

• Freeport, Texas : 3,200 MM LBS per yea• Louisiana (before expansion) : 1,300 MM LBS per yea

(after expansion) 2,600 MM LBS per yea

 SHIN-ETSU JAPAN : 1,210 MM LBS per yea CIRES PORTUGAL : 440 MM LBS per yea SHIN-ETSU PVC NETHERLANDS

: 990 MM LBS per yea

 Total PVC Production Capacity : 8,440 MM LBS per 

(after expansion) (approx. 4 million Tons)
CHANGE IN THE CAPACITY IN THE USA (M

2009

Shintech 5,800 (35%)Oxyvinyl 3,653 (22%)Georgia Gulf 2,653 (16%)Formosa 2,524 (15%)Westlake 1,526 (9%)Certainteed 481 (3%)Dispersion/Copolymer 655 (4%)

17,292
Shintech uses the state-of-the-art PVC pro

technology developed by Shin-Etsu

 Shin-Etsu technology

- is used for about 18% of world’s PVC resin prod- is adopted by 12 International Licensees worldw

 Precision PVC resin through computer control Consistency from large reactors Quality from anti-fouling reactor design ISO 9001 and 14001 standards certified
SHINTECH

 Brief History

1974 Freeport Plant start-up2000 Addis Plant start-up2008 Plaquemine Chlor-Alkali/VCM/PVC plants start up

 Operation Outline

Corporate office -Houston, TXPlant Location -Freeport, TX / about 800 Acres(3.1 million)

- Addis, LA / about 1,200 Acres(4.8 million)- Plaquemine, LA/ about 3,100 Acres (12.6 mi

Facility - 3 Independent PVC Production P

Total PVC Capacity (Jan ’07) - 5,200 Million lbs/yr (2 million MT) Employees (Apr ’07) - 453

PVC MACT Testing Plan Prop

 Shintech has proposed to utilize th

results from one site as the representative data for all three si

 The uniform technology used thro

each site provides a redundancy e

 The proposed production grade is 

majority of product manufactured

 The only difference among the sit

production scale